One Uber as a digital business location?
Based on the concrete example of Uber , the aim of this paper is to find answers to the following questions: Can users play a decisive role in the value creation of a company in the digital economy? And if so, how can they be used to address the challenges of taxation in the digital economy?
The Liechtenstein "Blockchain Law" (TVTG) from the perspective of tax consulting
The article shows that although there is now a legal basis for the token economy in Liechtenstein, no adjustments to the tax law are necessary. This is because the economic approach to tax law means that a situation can be subsumed and assessed from a tax perspective regardless of the technology used.
The Liechtenstein private law establishment with divided or undivided capital
The Liechtenstein private law establishment is a very versatile and flexible legal form which is unknown under Swiss company law and cannot generally be assigned to corporations or foundations. The article deals with the "establishment" as a special feature of Liechtenstein company law.
Taxation of spouses in international relations
An "international" spouse relationship from a tax law perspective exists if only one spouse is subject to unlimited tax liability in Switzerland, while the other spouse has no or only limited tax liability in Switzerland. It must also be a legally and factually unseparated marriage. The taxation of such "international" spousal relationships is opposed by the addition of factors as prescribed by law. However, according to the established case law of the Federal Supreme Court, the latter - unlike in intercantonal relations - cannot create any tax liability in Switzerland.
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Consultation agreement with Germany on the taxation of railway staff
On 13 May 2020, the State Secretariat for International Financial Matters SIF concluded a new consultation agreement between Switzerland and Germany on the taxation of railway personnel.
SIF publishes peer review report of the Global Forum
On 6 April 2020, the State Secretariat for International Financial Matters (SIF) published the peer review report on the exchange of information upon request for tax purposes.
FTA - Key figures on international administrative assistance
On 27 February 2020, the Federal Tax Administration updated the key figures on international administrative assistance in 2019.
OECD publishes report on transfer prices in financial transactions
On 11 February 2020, the Organisation for Economic Cooperation and Development (OECD) published a report containing guidelines on the transfer pricing aspects of financial transactions.
OECD publishes statement on taxation of multinational companies
On 31 January 2020, the Organisation for Economic Cooperation and Development (OECD) published a statement on taxation of multinational (digital) companies, according to which an agreement should be in place by the end of 2020 (see also taxlawblog contributions of 12 October 2019 and 9 November 2019).
SIF updates list of DTAs with abuse provisions
On 17 January 2020, the Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) updated the list of agreements with abuse provisions.
Federal Council opens consultation on the Federal Act on the Implementation of International Tax Treaties
At its meeting on 13 December 2019, the Federal Council opened the consultation process on the Federal Act on the Implementation of International Agreements in the Tax Field (new StADG). The consultation period will last until 27 March 2020.
BEPS Convention entered into force on 1 December 2019
The Multilateral Agreement on the Implementation of Agreement-Based Measures to Prevent the Reduction and Transfer of Profits ("BEPS Agreement") has been in force since 1 December 2019. With the help of the Convention, existing double taxation agreements can be adapted to the recommendations from the BEPS project.
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Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on August 30, 2022, entitled "Restitution in International Relations - Current Practice and Problem Areas".
International transactions involving intellectual property
Workshop by Napoleão Dagnese, Balthasar Denger and Thomas Hug on the occasion of the ISIS) seminar on 27 June 2022 entitled "International transactions involving intellectual property".
